DCT
0:24-cv-03091
Ardisam Inc v. Clam Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ardisam, Inc. (Wisconsin)
- Defendant: Clam Corporation (Minnesota)
- Plaintiff’s Counsel: Perkins Coie LLP
- Case Identification: 0:24-cv-03091, D. Minn., 08/01/2024
- Venue Allegations: Venue is asserted based on Defendant being headquartered in the district, having offices and physical business facilities in the district, and placing the accused products into the stream of commerce in the district.
- Core Dispute: Plaintiff alleges that Defendant’s line of portable sled shelters infringes a patent related to deployable frame structures and hinge mechanisms for such shelters.
- Technical Context: The technology concerns portable shelters, often used for ice fishing, which feature a fabric shell over a collapsible frame mounted on a sled base for transport.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of infringement via a letter dated April 25, 2024, approximately three months prior to filing the lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2020-12-24 | ’297 Patent Priority Date |
| 2024-04-16 | ’297 Patent Issue Date |
| 2024-04-25 | Plaintiff sends notice letter to Defendant |
| 2024-08-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,959,297 - "Portable Shelters"
- Patent Identification: U.S. Patent No. 11,959,297, "Portable Shelters", issued April 16, 2024.
The Invention Explained
- Problem Addressed: The patent describes a problem with conventional portable shelters where elements of the frame structure obstruct side doors, which hinders ingress and egress for the user, particularly when gear is positioned inside (’297 Patent, col. 1:26-33).
- The Patented Solution: The invention is a stowable and deployable shelter with a specific frame architecture designed to create an unobstructed side opening. This is achieved using a system of support arches, including a "cantilevered arch" that pivots from a "middle roof arch" via a hinge (’297 Patent, col. 3:52-65). This hinge is positioned to elevate the cantilevered portion of the frame above the side opening, as illustrated in the patent's Figure 2 (’297 Patent, col. 4:37-46). In some embodiments, the hinge is slidable along a support arch, allowing it to move from a stowed position near the base to a deployed, elevated position (’297 Patent, col. 5:26-44).
- Technical Importance: This design purports to provide the convenience of a side door without the structural obstructions found in prior art shelters, thereby improving user access (’297 Patent, col. 8:37-43).
Key Claims at a Glance
- The complaint asserts independent claims 1, 8, and 16 (’297 Patent, col. 9:26-11:51; Compl. ¶22).
- Independent Claim 1: Recites a shelter system with a container and four specific arches (first, second, third, and fourth). It requires that the third arch have a telescoping joint and a catch, and connects to the fourth arch via a specific hinge that comprises a hinge body with a passageway and a detent element.
- Independent Claim 8: Recites a similar four-arch system with a hinge and catch mechanism. It adds limitations for a "pole" positionable between various arches and requires that a door in the flexible shell be positioned "beneath the fourth arch."
- Independent Claim 16: Recites a more broadly defined system with a "base," a "frame structure" comprising a "plurality of first support arches" and a "second support arch" attached via a hinge. It requires the hinge to move from a first distance to a second, greater distance from a pivot point during deployment.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused products are a line of Clam’s sled shelters, including the Jason Mitchell XT Thermal, Nanook XT Thermal, Yukon XT Thermal, Voyager XT Thermal, X200 Thermal XT, and Legend XT Thermal series, among others (Compl. ¶13).
Functionality and Market Context
- The accused products are portable, deployable shelters for outdoor use, such as ice fishing (Compl. ¶12). They consist of a fabric shell supported by a frame, mounted on a sled-style base that facilitates transport across snow and ice (Compl. ¶14). The complaint provides an image of an accused two-man shelter, the "Jason Mitchell XT Thermal," which shows a sled base and a deployed frame and shell structure (Compl. ¶14). A similar image is provided for an accused one-man shelter, the "Legend XT Thermal" (Compl. ¶15).
IV. Analysis of Infringement Allegations
While the complaint incorporates infringement claim charts by reference as Exhibits B and C which were not provided, the following table summarizes the infringement allegations for a representative claim by mapping its elements to the accused products as generally described in the complaint (Compl. ¶¶12-15, 22).
’297 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) a container; | The sled base of the Accused Products, which supports the frame structure. An example is shown in the image of the Jason Mitchell XT Thermal shelter. | ¶13, ¶14 | col. 3:20-28 |
| (b) a first arch pivotably attached to the container...to extend from the container and rest on a surface; | A frame member of the Accused Products that pivots from the sled base to extend outward and contact the ground/ice surface. | ¶13, ¶22 | col. 3:36-45 |
| (c) a second arch pivotably attached to the container...to extend upwardly from the container; | A frame member of the Accused Products that pivots upward from the sled base. | ¶13, ¶22 | col. 3:36-45 |
| (d) a third arch pivotably attached to the container...[comprising] a first telescoping joint...[and] a catch...; | A frame member of the Accused Products that pivots upward and allegedly includes a telescoping extension mechanism and a catch (hole or depression). | ¶13, ¶22 | col. 5:9-13; col. 5:21-25 |
| (e) a hinge positioned on the third arch; | A hinge mechanism on a frame member of the Accused Products. An illustration of this concept is reproduced in the complaint from the patent's Figure 2. | ¶8, ¶13, ¶22 | col. 5:26-30 |
| (f) a fourth arch pivotably attached to the third arch via the hinge...; | A cantilevered frame member of the Accused Products that is allegedly attached via the aforementioned hinge. | ¶13, ¶22 | col. 3:52-60 |
| (g) a flexible shell positionable over at least the third arch and the fourth arch; | The fabric covering of the Accused Products that forms the shelter's enclosure. | ¶13, ¶22 | col. 4:18-21 |
| wherein...the hinge comprises: a hinge body comprising a passageway...a detent element...positionable to engage the catch; and a shaft... | The complaint alleges infringement of claims containing these limitations, implying the Accused Products' hinge mechanisms contain these specific structural components. | ¶22 | col. 6:40-54 |
Identified Points of Contention
- Scope Questions: A central question may be how the claim terms "first arch", "second arch", "third arch", and "fourth arch" map onto the physical poles of the accused shelters. The analysis may differ for Claim 16, which uses the more general terms "first support arches" and "second support arch".
- Technical Questions: The complaint does not provide specific evidence showing that the accused products' hinge mechanism contains all the elements required by the claims, such as a "passageway through which the first arm passes" and a "detent element" that engages a "catch." The existence and operation of this specific locking hinge structure in the accused products will likely be a key factual dispute.
V. Key Claim Terms for Construction
The Term: "hinge"
- Context and Importance: This term is critical because the asserted claims recite a specific hinge structure as the connection point for the cantilevered arch that creates the unobstructed side opening. Claim 1, for example, defines the hinge as comprising a "hinge body," a "passageway," a "detent element," and a "shaft." The infringement analysis will depend on whether the connecting mechanism in the accused products meets this detailed definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent uses the term "hinge" generally in the summary and description to refer to the pivotable connection between arches (’297 Patent, col. 2:42).
- Evidence for a Narrower Interpretation: The claims themselves provide a specific definition for the "hinge", requiring multiple sub-elements (’297 Patent, col. 10:57-65). The specification provides a detailed embodiment of this hinge, including a locking mechanism with a detent, button, and spring, as shown in Figure 5 (’297 Patent, col. 6:40-54). This may suggest the term is limited to the specific structures disclosed.
The Term: "catch"
- Context and Importance: Claims 1 and 8 require a "catch" on one of the arches, defined as a "hole or depression," for the hinge's detent element to engage. The existence of this specific feature on the accused products' frame poles will be a required element for a finding of literal infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "catch" could be argued to cover any feature that mechanically stops the hinge's movement, not just a literal hole.
- Evidence for a Narrower Interpretation: The claim language explicitly defines the catch as "a hole or depression in the first arm," and the specification describes its function as engaging with the detent element of the locking mechanism to hold the hinge in a specific location (’297 Patent, col. 5:21-25; col. 6:55-62).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by asserting that Clam "instructs and induces its customers to use the Accused Products in a manner that directly infringes" the ’297 patent (Compl. ¶23). It also alleges contributory infringement, stating the products are not staple articles of commerce suitable for substantial noninfringing uses (Compl. ¶23).
- Willful Infringement: Willfulness is alleged based on Clam's purported knowledge of the ’297 patent and its infringement "since at least as early as April 26, 2024," the date it allegedly received a notice letter from Ardisam (Compl. ¶19, ¶24).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of structural correspondence: Does the hinge mechanism in Clam's accused shelters contain the specific components—a body with a passageway, a detent element, and a catch in the form of a hole or depression—as explicitly recited in independent claims 1 and 8 of the ’297 patent?
- A key question of claim scope will be how the different terminologies for the frame members in Claim 1 ("first," "second," "third," and "fourth" arches) versus Claim 16 ("plurality of first support arches" and "a second support arch") are construed and applied to the physical structure of the accused products.
- An important evidentiary question will be what proof is offered to demonstrate that the accused shelters practice the "slidable" or "translating" hinge functionality described in the patent specification and required by limitations in claims like Claim 16, which requires the hinge to move between two different distances from a pivot point during deployment.